ML20070L993
| ML20070L993 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/04/1983 |
| From: | Maurin L LOUISIANA POWER & LIGHT CO. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-82-109, W3I83-0002, W3I83-2, NUDOCS 8301120183 | |
| Download: ML20070L993 (8) | |
Text
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- NEW ORLIANS. LOUISIANA 70174 * (504) 366-2345 EuSESY$
L. V. MAURIN January 4, 1983 Vee Pres &nt Nuckvir Operations W3I83-0002 Q-3-A35.02.01 Mr. Richard C. DeYoung Director of Inspection & Enforcement US Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Waterford 3 SES Request for Mitigation of Civil Penalty
REFERENCE:
Docket No. 50-382 Construction Permit: CPPR-103 EA 82-109 December 6, 1982
Dear Mr. DeYoung:
In accordance with 10CFR 2.205, LP&L requests that NRC review the circum-stances concerning the proposed civil penalty of $20,000 and reconsider whether a civil penalty is warranted.
Based upon our assessment of the five factors contained in Section IV (B) of 10CFR Part 2, Appendix C as described in the attached document, LP&L suggests that complete mitigation of the penalty is in order. This would seem partic-ularly appropriate here since (1) NRC has stated that civil penalties are not normally assessed for Level 3 violations (47 FR 9989); and (2) the deficiency was identified by LP&L, it was reported by LP&L to NRC, prompt corrective action by LP&L has been acknowledged by NRC and the deficiency has not been the subject of any prior notice of violation (47 FR 9991).
As we understand NRC's enforcement policies, under circumstances such as these, applicants are to be encouraged for their identification and correction of problems not penalized.
Yours very truly, L. V. Maurin ec:
Mr. John T. Collins Regional Administrator USNRC Region IV Mr. E. L. Blake Mr. W. M. Stevenson 8301120183 830104
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Mr. Richard C. DeYoung W3183-0002 Page 2 bec:
R. Barkhurst, R. K.' Stampley (2), F. J. Drummond, T. F. Gerrets, C. J..Decareaux, T. K. Armington, L. L. Base, R. W. Prados, Central Records, L. V. Maurin, G.-B. Rogers, Nuclear Records, Licensing Library, R. A. Savoie. W. A. Cross, G. D. McLendon,
-S. A. Alleman, W. M. Morgan, G. L. Constable (NRC), W. F. Axtman, J. Gutierrez, L. A. Stinson, M. Clary, Z. Sabri, R. Burski, K. Iyengar, M. Meyer, Ebasco L
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I Mr. Richard C. DeYoung W3I83-0002 I. PROMPT IDENTIFICATION AND REPORTING A.
Length Of Time The Violation Existed Prior To Discovery.
During the spring of 1982 the first major piping and instrumentation safety-related systems were approaching construction completion at which time quality record verification commenced. The status of physical completion and finalization of quality documentation was considered to be sufficiently complete to begin pre-operational testing and hence, systems were being submitted for LP&L review to determine the acceptability of the system for required start-up tests. Louisiana Power & Light Company's action to reject the four subject safety-related mechanical and instrumentation systems was taken on the first such systems submitted for turnover.
It is further noted that both the installing contractor and Construction Manager had already identified numerous physical exceptions and quality documentation exceptions with each of these four systems.
Based on the above, it is Louisiana Power & Light Company's position that the problem identification was made at the earliest time practicable through LP&L audits.
B.
Opportunity To Discover The Violation 1.
Construction Manager Review and Acceptance of Quality Documentation -
)I The four subject safety-injection systems were the first four major safety-related systems processed by the Construction Manager and submitted to Louisiana Power & Light Company for turnover acceptance. Louisiana Power & Light Company's initial review of these systems identified problems in the adequacy of the review.
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2.
Instrumentation Installation Sub-Contractor -
i The four subject safety-injection systems were the first safety-related instrumentation systems documentation packages submitted by the instrumentation installation contractor for turnover acceptance. Prior to the time of submittal of the documentation packages, each of the inetrument installations j
were still in an "in-process" status (not accepted by the t
installing contractor Quality Assurance organization).
4 The nature of instrumentation installation is such that the instrumentation is not in a final configuration as long as t
construction work or corrective rework is in process.
It is concluded that the identification of the problems associated with instrumentation installation on a completed instrument loop basis was identified at the earliest practicable opportunity.
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a Mr. Richard C. DeYoung W3I83-0002 Page 2 I. PROMPT IDENTIFICATION AND REPORTING (Continued)
B.
Opportunity to Discover The Violation (Continued) 3.
Piping and Support System Installation Contractor -
Acceptability of piping system supports is programmatically keyed to the acceptability of the installation relative to the final design engineering approved as-built of each support.
Final quality documentation is also reviewed and verified relative to the final as-built. Engineering final as-built drawings only came available during the spring of 1982.
Problems with piping system supports fall into two (2) categories. First, the problems identified with the final support configuration and as-built documentation were identified by LP&L on the first major safety-related system turnover and at the earliest practicable opportunity.
The second problem associated with piping support installation is the problem of under-sized welds. A detailed physical inspection of the hangers at an earlier date by LP&L could possibly have identified this problem. However, the problem of undersized welds is associated with small localized areas of undersize and surveillance inspection of hangers and hanger installation audits were unlikely to have identified this type of problem.
The problem is identified only during a detailed weld-by-weld inspection of the installation. Relatively few hangers have been identified for which welding was a serious problem (serious in the context that the weld undersize should have been readily obvious).
C.
Promptness And Completeness Of Any Required Report Louisiana Power & Light Company considers that it promptly and completely identified these problems to the Nuclear Regulatory Commission.
4 4
. Nr. Richard CE DeYoung.
'Page,
II. CORRECTIVE ACTION TO PREVENT RECURRENCE 1
h A..
Timeliness of Corrective Action -
Louisiana Power & Light Company considers that corrective action for-these problems was initiated in a timely and responsive manner.
Specifically the following actions were promptly taken.
i, Mercury Company (a) Mercury crafts were reassigned off safety-related systems work on June 23, 1982'to implement a reindoctrination/re-orientetion program.
(b) Teams were identified and instructed to proceed with i
reinspection / rework activities (after retraining) for
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acceptable construction completion.
(c) LP&L QA was directly involved in the development of a documented retraining program which was completed and 4
. approved on June 25, 1982. The Mercury program includes training for records review, QC inspector, craft,'
and engineering personnel.
1 (d) ' Implementation of retraining the reinspection / rework teams identified in (b) above was begun on June 26, 1982.
e (e) Ebasco/LP&L concurrence of proper execution of the retraining program was accomplished on June 29, 1982.
y (f) A meeting with LP&L, Ebasco and Mercury was held June j
24, 1982 to discuss reorganization. The recommended organizational changes were implemented June 25, 1982.
(g) Mercury increased their documentation review staff and t
quality control inspection personnel.
l Tompkins-Beckwith (a) Tompkins-Beckwith has completed a retraining program with particular emphasis on as-built records reviews for all.
Hanger Engineering personnel and Quality Control inspectors to requalify them to properly perform the field inspections of pipe supports / restraints and to complete the necessary documentation.
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Page 4 II. CORRECTIVE ACTION TO PREVENT RECURRENCE A.
Timeliness of Corrective Action - (Continued)
(b) Tompkins-Beckwith Quality' Control and Engineering initiated a reinspection of approximately 5,000 hangers which had-been completed and accepted prior to July 6, 1982. NCR, W3-4010 was issued to track and document the disposition and corrective action taken for hangers found to have deviations from design requirements.
(c) A Tompkins-Beckwith Quality Assurance Audit is conducted monthly to review a sample _ lot of hangers to verify that the reinspections and future inspections are properly performed.
(d) Ebasco Services Incorporated has completed a retraining program for Ebasco Quality Assurance personnel involved in the review of piping hanger documentation and conducts an on-going training / retraining program.
(e) Tompkins-Beckwith increased their document review and quality control inspection staffs.
I B.
Degree of Licensee Initiative
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Louisiana Power & Light Company considers that its Quality Program managerial actions have been appropriate and responsive. The problems which are the subject of this report were identified by Louisiana Power & Light's Quality Assurance and Start-up personnel and the problems were promptly reported to the Nuclear Regulatory Commission. Corrective actions taken and still in progress involve all Quality Assurance tiers at the Waterford 3 site. Louisiana Power
& Light's corrective action plan and its implementation is considered to be aggressive and responsive to the situation identified.
C.
Comprehensiveness of the Corrective Action -
Louisiana Power & Light Company considers that the corrective actions taken and underway are responsive and appropriate. Specifically the following comprehensive actions were taken:
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Mr. Richard C. DeYoung W3I83-0002 Page 5 II. CORRECTIVE ACTION TO PREVENT RECURRENCE C.
Comprehensiveness of the Corrective Action - (Continued)
(a) Mercury Company - An extensive training / retraining program was implemented by Mercury for their records review, QC inspector, crcft, and engineering personnel. This program will continue in order to maintain the proficiency of these personnel. Joint system walkdowns with Mercury and Ebasco were initiated for the purpose of problem identification and resolution prior to system release and turnover. Additionally,-Mercury has increased their documentation review and quality control inspection staffs.
(b) Tompkins-Beckwith - Ebasco Services, Inc. has retrained the personnel involved in the review of piping hanger documentation.
Both Ebasco and Tompkins-Beckwith have increased their documentation review, quality control and supervisory staffs which has resulted in an improved level of quality.
Training / retraining efforts will continue in order to maintain the proficiency of these personnel. Tompkins-Beckwith and Ebasco Quality Assurance have performed hanger installation surveillances, which will continue through the system release and turnover process. Additionally, Tompkins-Beckwith is performing monthly hanger inspection program audits.
(c) Ebasco - With LP&L's concurrence Ebasco formed a QA Surveillance Group to increase Quality Assurance involvement in in-process construction activities including hardware installation, walkdown inspections, system testing and system turnover. A major objective of this group is to perform random physical inspections to assure contractor compliance to established requirements.
(d) LP&L - The LP&L QA organization has been enlarged and supple-mented with contract personnel in order to provide broader QA coverage of safety related site activities.
Quality Assurance has developed procedures and will conduct audits to verify system configuration and documentation prior to turnover to LP&L Startup. Plant staff, in conjunction with startup engineers, will perform system walkdowns and will verify the status of the current as-built configuration of the system prior to transfer to the plant staff. These measures will provide assurance of the quality and readiness of systems to support safe plant operations.
Responsibility for Significant Construction Deficiency, l
Inspection Reports, and other required reporting has been transferred from QA to Licensing. This permits more time for direct involvement by LP&L QA in construction activities.
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Mr.' Richard C. DeYoung W3I83-0002 Page 6
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III. ENFORCEMENT HISTORY Louisiana Power & Light Company considers that the Enforcement History on the Waterford 3 Project can be rated between " good" and " exceptional."
Louisiana Power & Light Company-bases this position on the fact that.cnt a project-to-date basis, Nuclear Regulatory Commission inspection findings have all been Severity Level 4 or 5 (NRC Inspection Report 82-14 being the first Severity Level 3 finding). Additionally, Louisiana Power & Light Company notes that with one exception, NRC SALP reports prior to the most recent have rated Louisiana Power & Light Company's Waterford 3 Quality Assurance Program in performance category 1 or 2.
The one exception pertained to the licensing category and focused on the need for increased staffing of personnel with more nuclear experience. The current NRC SALP report includes the time period during which the subject problem was identified and the lower ratings in the SALP report are duc at least in part to the problems identified in EA 82-109 and IE Report 50-382/82-14.
IV.
PRIOR NOTICE OF SIMILAR EVENTS NONE V.
MULTIPLE OCCURRENCES Louisiana Power & Light Company is proud of the history of its Quality Assurance Program and its implementation on the Waterford 3 site. On a project-to-date basis, major problems have been avoided and all problems of a potentially serious nature have been aggressively addressed.
Louisiana Power & Light Company considers that no major or potentially serious problems have been allowed to recur.
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